RECEIVED
BEFORE THE
POSTAL RATE COMMISSION
POSTAL RATE AND FEE CHANGES,
2000
:
FEB 15
9 44
DOCKET NO. R2000-1
SECOND SET OF INTERROGATORIES
FROM
UNITED PARCEL SERVICE TO UNITED STATES
POSTAL SERVICE WITNESS BOZZO
(UPS/USPS-T152
through 8)
(February 15, 2000)
Pursuant to the Commission’s
serves the following interrogatories
Bozzo:
UPS/USPS-T1
Rules of Practice, United Parcel Service hereby
directed to United States Postal Service witness
5-2 through 8.
Respectfully
submitted,
;~~~$;~;ygLjj
William J. Pinamont
Phillip E. Wilson, Jr.
Attorneys for United Parcel Service
Piper Marbury Rudnick &Wolfe LLP
3400 Two Logan Square
18th & Arch Streets
Philadelphia, PA 19103-2762
(215) 656-3310
(215) 656-3301 (FAX)
and
1200 Nineteenth Street, NW
Washington, DC 20036-2430
(202) 861-3900
Of Counsel.
JIM‘00
INTERROGATORIES
OF UNITED PARCEL SERVICE
TO UNITED STATES POSTAL SERVICE WITNESS BOZZO
UPS/USPS-T1
5-2. For the Installation
94 of your testimony:
Master File referred to at pages 89 and
”
(a)
List the full set of variables contained
in the file, along with their
(b)
Indicate the time period covered by the file;
(c)
Describe the unit of observation,
definitions;
that is, the entity to which
individual records in the file correspond;
(4
Describe the universe of installations
(e)
Provide any manuals or other documentation
UPS/USPS-T1
5-3. For the Management
contained
Operating
in the file; and
available for the file.
Data System initially referred
to at page 1 of your testimony:
(4
List the full set of variables contained
in the file, along with their
@I
Indicate the time period covered by the file;
(c)
Describe the unit of observation,
definitions;
that is, the entity to which
individual records in the file correspond;
(4
Describe the universe of installations
(6
Provide any manuals or other documentation
UPS/USPS-T15-4.
For the Address Information
contained
in the file; and
available for the file.
System referred to at pages 89-
90 of your testimony:
(a)
List the full set of variables contained
definitions;
-l-
in the file, along with their
INTERROGATORIES
OF UNITED PARCEL SERVICE
TO UNITED STATES POSTAL SERVICE WITNESS BOZZO
@I
Indicate the time period covered by the file;
(c)
Describe the unit of observation,
that is, the entity to which
individual records in the tile correspond;
(4
Describe the universe of installations
(e)
Provide any manuals or other documentation
UPS/USPS-T15-5.
contained
For the Address List Management
in the file; and
available for the file.
System referred to at
pages 89 and 90 of your testimony:
(a)
List the full set of variables contained
in the file, along with their
(b)
Indicate the time period covered by the file;
(c)
Describe the unit of observation,
definitions;
that is, the entity to which
individual records in the file correspond;
04
Describe the universe of installations
(e)
Provide any manuals or other documentation
UPS/USPS-T15-6.
For the National Workhour
contained
in the file; and
available for the file.
Reporting System referred to at
pages 89 and 91-92 of your testimony:
(a)
List the full set of variables contained
in the file, along with their
(b)
Indicate the time period covered by the file;
(cl
Describe the unit of observation,
definitions;
individual records in the file correspond;
-2-
that is, the entity to which
INTERROGATORIES
OF UNITED PARCEL SERVICE
TO UNITED STATES POSTAL SERVICE WITNESS BOZZO
(4
Describe the universe of installations
(e)
Provide any manuals or other documentation
UPS/USPS-T1
contained
in the file; and
available for the file.
5-7. For the Personal Property Asset Master referred to at pages
89 and 93-94 of your testimony:
(a)
List the full set of variables contained
in the file, along with their
0))
Indicate the time period covered by the file;
(c)
Describe the unit of observation,
definitions;
that is, the entity to which
individual records in the file correspond;
(4
Describe the universe of installations
(e)
Provide any manuals or other documentation
UPS/USPS-T1
contained
in the file; and
available for the file.
5-8. For the Facility Master System referred to at pages 89 and
93 of your testimony:
(a)
List the full set of variables contained
in the file, along with their
(b)
Indicate the time period covered by the file;
(c)
Describe the unit of observation,
definitions;
that is, the entity to which
individual records in the file correspond;
(4
Describe the universe of installations
(e)
Provide any manuals or other documentation
-3-
contained
in the file; and
available for the file.
CERTIFICATE
OF SERVICE
I hereby certify that I have this date served the foregoing
mail, postage prepaid, in accordance
document
with Section 12 of the Commission’s
by first class
Rules of
Practice.
Attorney for United Parcel Service
Dated: February 15, 2000
Philadelphia, Pa.
59282